Summer is in full swing and that means (at least for us) that things are a little slower around the office. What better time to revisit some of the news that we didn't get to tackle during the frantic spring season?

Today, we look back at how women's clothing company Eileen Fisher has responded to California's newly implemented "Transparency in Supply Chain Act," which requires retailers and manufacturers with annual sales of $100 million or more that do business in California to disclose their efforts to eliminate human trafficking and slavery from their supply chain.

Among the California requirements are actions to ensure disclosure of "to what extent if any" a company engages in the five following activities: verification, auditing, certification, internal accountability, and training.

In Social Accountability International's February 2012 newsletter, Eileen Fisher's Human Rights Associate Lina Lee reflected on what the new law meant to the company. We thought it was interesting because Eileen Fisher is already known for its commitment to sustainability and wasn't starting from scratch. It's also a midsize business, and so it doesn't have the resources of a Nike or Adidas to ensure that human rights are respected throughout its supply chain. What lessons might other midsize companies take from Eileen Fisher's example?

Here are a few snippets that caught our attention:

Recently, we decided to incorporate a 'social tech' sheet into our fabric and yarn approval process, in addition to the regular tech sheet and eco tech sheet. The purpose of this tech sheet is to gather information related to certain raw materials that might be associated with human rights or animal welfare issues before a bulk order is placed.

Lesson: Consider asking vendors (both current and prospective) about their social protections. What systems do they have in place to prevent underage employment, abusive working conditions, and unfair wages? What are your direct suppliers doing to reach out to *their* suppliers. Simply asking these questions can create momentum all along the supply chain.

We also started participating in design meetings to help inform our designers on issues related to certain raw materials. Since this design for decent work approach is a new process, it will be interesting to see what challenges we will face when we come to the intersection of business versus values.

Lesson: Integrate social sustainability into your product design process. For example, conflict minerals are heating up as a big topic of concern and you need to know if/how those materials may be used in the manufacturing/processing of your products. Talk to your designers to understand how social sustainability overlaps with your current product line, and how to optimize the next iteration of products to better address these issues.

We sent a letter to all of our first tier suppliers (31 total) to inform them about the law, along with some educational materials on the topic and the supplier's country law on the issue. We also asked them to fill out a survey to help us assess where we could be vulnerable to human trafficking and slavery in our supply chain.

Lesson: While *you* might know all about your sustainability obligations, your suppliers may not. Take the time to educate them. And while you're at it, ask them how they can help you. Many times they will WANT to be more proactive, but aren't sure if you care. Make it clear that you would love their help!

We've helped clients address the new requirements of the California Transparency in Supply Chains Act. If you'd like to learn more, please contact us for a complimentary consultation to discuss where you are vulnerable, what systems you may need to put in place, and what communications will be required for compliance.